International Tax Law / Transfer Pricing

International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law
23.02.2024 | Dr. Carsten Quilitzsch LL.M., Dr. Gabriel Hörnicke LL.M., Dr. Stefanie Rötting LL.M.
Position of the German tax authorities on Service PEs
A permanent establishment (“PE”) is a key factor in establishing a limited tax liability in Germany. Also, German trade tax depends on the existence of a PE in Germany.…
International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law
23.02.2024 | Dr. Christoph Klein, Yannick Barbu LL.M., Licencié en droit
New administrative guidance on „home office“ permanent establishments
Have we escaped the daily commute? Remote working has significantly increased in recent years, accelerated by the recent pandemic. More and more companies have been…
International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law
23.02.2024 | Prof. Dr. Sven-Eric Bärsch, Dr. Daniel Keuper M.Sc.
German tax authorities specify requirements for permanent establishments
Due to their function as a tax nexus, the existence ("whether") of international permanent establishments (“PEs”) is increasingly becoming a reason for tax disputes with…
International Tax Law / Transfer Pricing
17.07.2023 | Christoph Hawlitschek LL.M. (San Francisco)
European Commission proposes FASTER Directive to optimise the process of withholding tax relief
Introduction On 19 June 2023, the European Commission published a proposal for a Council Directive “On Faster and Safer Relief of Excess Withholding Taxes”, or simply…
Internationales Steuerrecht mit Bezug zu den Balearen
International Tax Law / Transfer Pricing
14.06.2023 | Prof. Dr. Sven-Eric Bärsch, Dr. Sven Kluge
BMF publishes Administrative Principles Transfer Pricing 2023
BMF publishes Administrative Principles Transfer Pricing 2023 On June 6, 2023, the German Federal Ministry of Finance (BMF) issued new administrative principles on…
International Tax Law / Transfer Pricing
23.12.2022 | Dr. Christoph Klein, Yannick Barbu LL.M., Licencié en droit
German registered IP: Adjustment to German sourcing rules
[Note: This post was updated on 23 December 2022] For the past two years, MNEs owning IP registered in Germany have been facing uncertainty with regard to the taxation of…
International Tax Law / Transfer Pricing
02.08.2022 | Dr. Christoph Klein, Yannick Barbu LL.M., Licencié en droit
German registered IP: Planned adjustment to German sourcing rules
For the past two years, MNEs owning IP registered in Germany have been facing uncertainty with regard to the taxation of payments for the licensing or sale of such IP…
International Tax Law / Transfer Pricing
30.06.2022 | Dr. Christoph Klein, Prof. Dr. Sven-Eric Bärsch, Dr. Marcus Oliver Mick LL.M. (Fordham Univers.)
Taxation of German registered IP
[Note: This post was updated on 29 June 2022] 2020 was eventful for MNEs with IP (e.g. patents, trademarks, etc.) registered in Germany due to the uncertainty surrounding…
International Tax Law / Transfer Pricing
04.03.2022 | Prof. Dr. Axel Cordewener LL.M., Dr. Christoph Klein
Tax Court of Munich on Withholding Tax Regime for Portfolio Dividends
In a recently published judgment of 6 December 2021, the Tax Court of Munich decided that the final German withholding tax (WHT) on German dividends to a Canadian pension…
Page 3/6